Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?
Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:
A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
Employees may not perform functions without appropriate training
Training may be provided by the hazmat employer or other public or private sources
A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered
Hazmat employee training must include the following:
General awareness/familiarization training
Security awareness training
In-depth security training
Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.
For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.
Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.
Call 888.442.9628 for more information. Have a problem? We have a solution.
ICC Compliance Center is excited to announce training dates for courses related to OSHA’s Hazcom 2012 (GHS standard). Classes are scheduled in our Niagara Falls, NY and Houston, TX training centers, and are soon to be scheduled around the country in the fall. We have four classes to choose from: A half-day General Awareness class; a one day “What’s Changed?”; a two day Manager/Supervisor class and a three day GHS Classification class. On-site training classes and webinars will be available soon.
We have four classes to choose from, depending on your interest. A half-day General Awareness, a one day What’s Changed, a two day Manager/Supervisor and a three day GHS Classification class.
Over the past few decades, the United Nations (UN) has been attempting to create a system with similar goals, that would be used (with possible minor modifications) on a world-wide scale. This system is called the Globally Harmonized System, or GHS.
OSHA has responded by modifying the hazard communication standard to reflect many of the concepts found in the GHS. These elements include: classification of hazardous substances, information to be provided on labels, and information to be found on material safety data sheets (or, as the GHS calls them, safety data sheets).
Training is the first deadline in the phased in final rule that was effective May 26, 2012. Training on the new elements must be completed by Dec 1, 2013.
ICC Compliance Center is proud to introduce onsite training in the Houston area. We currently provide various types of hazardous materials/dangerous goods training and certification to meet our customers’ requirements, including live-classroom, web-based or instructor-led webinars and onsite training.
Our regulatory specialists will come to a location of your choice, eliminating any travel expenses for your employees (ex. gas, airfare, hotel, rental car and dining).
Our experienced staff can develop and deliver many types of programs created especially for your company’s individual dangerous goods and hazardous materials requirements (products, modes of transport, shipping systems, etc.), together with practical suggestions for effective implementation.
Customized Onsite Training Gives You Control Over:
Class location, size and audience
Class schedule – schedule the training around your company’s workload
Confidential information – With only your employees present, sensitive and proprietary issues can be addressed and used as examples during class
Course retention – Studies have proven workers are able to learn more when they study together. The effects of a shared training experience continue long after the seminar has ended
David Lyle Ford has recently joined our team as a Regulatory Specialist, and specializes in dangerous goods, i.e. CFR 49, TDG, IATA, and IMDG. David came to ICC from a global petrochemical manufacturer where he was responsible for all modes of transport including railroad, highway, sea and air, with bulk and non-bulk transportation containers.
In addition to teaching regulations for CFR 49, TDG, IATA, and IMDG, David will utilize his strong experience to assist you and your team with:
Handling the complexities of trans-loading and help you reduce the liability and safety risks involved in bulk transport,
Preparing for an emergency incident before it happens. This includes assisting you in creating a plan that ensures employers and workers have the necessary equipment, know where to go, and know how to keep safe when an emergency occurs
David’s vision is to provide training that is easy to understand and guidance on how to ship dangerous goods safely.
I attended the sixth Dangerous Goods Instructor Symposium (DGIS VI) hosted by LabelMaster in Memphis TN last week.
Things started on Tuesday evening with the Dangerous Goods Trainers Association (DGTA) meeting. The changes concerning NESHTA, BCSP, IHMM and others were discussed. Bob Richard has suggested the DGTA make application at the UN for consultative status. This would allow DGTA to attend the UNSCOE on TDG as observers or as a NGO (non-governmental organization). The website has been updated, see www.dtga.org/. There was also discussion on which trade shows that DGTA should attend.
Later that night some of us boarded buses to go the the FedEx world hub. Here we were given a tour of the FedEx Memphis Hub (night-side) facilities.
Some interesting points of interest:
handles approx. 1.3 million packages daily
averages 140 landings per night (every 90 seconds)
averages 140 takeoffs per night
aircraft unloaded in under 30 minutes
fleet of more than 366 aircraft (727s to A300s to 777)
7,000 employees at the hub
covers 863 acres
approx. 42 miles (68 km) of conveyor belts
Thanks to David Jones of FedEx for arranging the tour.
The Wednesday morning session on the ABCs of Training Objectives. This workshop covered the basics in making brief, concise, clear learning objectives. After lunch, Howard Skolnik of Skolnik Industries did a hands-on session on Writing of packing and closure instructions: an exercise in authorship. Howard gave each table an exercise on writing an instruction for a simple every day function. Our table were to write a procedure for tying shoelaces. Another table got the wine bottle with corkscrew (the bottle was empty), another on how to fold a fitted sheet, and another on how to blow up a balloon. You can imagine the fun that was created with this exercise! Howard then made available different packaging examples to each table and we had to write the closure instructions. This was a great exercise, we just did not have enough time to complete the exercises. The last session dealt with our Pet Peeves in the regulations. Some examples that came up were:
why does ICAO require 2 technical names and IATA does not?
49 CFR: is it basic description or shipping description or description when it comes to describing the dangerous goods that are to be shipped?
are closure instructions necessary for compressed gas cylinders?
IMDG: when listing several paints with different flash points, which flash point gets listed on the shipping document?
ICAO A69: forces the shipper to recognize mercury as dangerous goods
Thursday began with an ICAO update from Geoff Leach, chair of the ICAO Dangerous Goods Panel. Over 100 papers have been submitted and each one has to be reviewed during the 8 days that have been scheduled for the 2013/2014 Technical Instructions session. Some of the issues that have been brought forward:
when it says “not subject to the Technical Instructions”, what does this really mean?
recurrent training going to calendar date
oxygen generators – the ValueJet crash needs to be kept in everyone’s mind; recent incident in Australia with these
EHS (environmentally hazardous substance): ICAO was too quick off the mark to align with the UN when other modes had not, going back to the 15th Edition to allow for transition
gross mass will only apply to LQ, definition of net mass means the article not the dangerous goods in it
class 6.1 subsidiary for mercury will be optional unless the content is > 5 kg
dangerous goods in crew baggage is not addressed, it will be the same as for passengers
undeclared vs misdeclared: undeclared means that there is no shipper’s declaration, mis-declared means it is not what it is
how to deal with Ebay, i.e. large lighter with 3 Li batteries flashlight in the handle
training for the load-master and security staff
reporting of dangerous goods that have not been loaded properly
changes to the NOTOC to simplify the form
Li batteries: remove section II, package according to the TIs
dangerous goods in helicopters
maximum spare batteries for passengers/crew is 2; this poses problems for those who have to use a nebulizer, etc.
by James Henry, CDGT, CET on December 4, 2009 at 3:10 pm · in Jim's Blog
Shipping lithium batteries has become a confusing issue. Let’s start by asking "what is a lithium battery?". There are two types of lithium batteries – metal and ion (polymer). The lithium metal battery is also termed "primary" which means non-rechargeable. Typically you find these batteries in watches, calculators, cameras, etc. Lithium ion (and polymer) are "secondary" or rechargeable batteries. These are found in mobile phones, laptop computers, satellite navigation units, etc.